PAHO's Code of Ethical Principles and Conduct

Presented to the 46th Directing Council (CD46/28)Code of Ethical PrinciplesAndConductApproved by the Director of PAHOPAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715

The United Nations and the specialized agencies embody the highest aspirations of thepeoples of the world. Their aim is to save succeeding generations from the scourge ofwar and to enable every man, woman and child to live in dignity and freedom.The international civil service bears responsibility for translating these ideals intoreality. It relies on the great traditions of public administration that have grown up inmember States; competence, integrity, impartiality, independence and discretion. Butover and above this, international civil servants have a special calling: to serve the idealsof peace, of respect for fundamental rights, of economic and social progress, and ofinternational cooperation. It is therefore incumbent on international civil servants toadhere to the highest standards of conduct; for ultimately, it is the international civilservice that will enable the United Nations system to bring about a just and peacefulworld.Standards of Conduct for the International Civil Service, 2001PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 2

TABLE OF CONTENTSI. SAFEGUARDING PAHO’S PRINCIPLES AND VALUES......................4A. INTRODUCTION............................................................................................................................. 4B. PAHO’S ETHICAL PRINCIPLES .............................................................................................. 4C. OBJECTIVES OF THIS CODE.................................................................................................... 5D. APPLICABILITY ............................................................................................................................. 5E. ACKNOWLEDGEMENT AND AGREEMENT.......................................................................... 6II. ETHICAL FRAMEWORK............................................................................7A. MAKING ETHICAL DECISIONS .............................................................................................. 7B. THE INTEGRITY AND CONFLICT MANAGEMENT SYSTEM (ICMS) ..................... 7III. CREATING A CULTURE OF COMPLIANCE AND PREVENTION.10A. PAHO’S PRIVILEGES AND IMMUNITIES........................................................................ 10B. RIGHTS, RESPONSIBILITIES AND OBLIGATIONS................................................... 10C. DUTY TO COMPLY ....................................................................................................................... 12D. REPORTING.................................................................................................................................... 12E. INVESTIGATIONS ....................................................................................................................... 13F. PROHIBITION AGAINST RETALIATION ......................................................................... 13IV. STANDARDS OF CONDUCT.................................................................14A. CONDUCT AFFECTING THE WORKPLACE....................................................................... 14B. CONFLICT OF INTERESTS ...................................................................................................... 16C. USE OF PAHO’S PROPERTY AND RESOURCES ............................................................ 24APPENDIX 1ACKNOWLEDGEMENT OF RECEIPT FORM..............29PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 3

• Transparency and fairness;• Respect for the dignity, worth and equality of others;• Independence from outside authorities; and• Tolerance for different cultures and perspectives.These basic principles are the guideposts against which our ethical behavior and conductis measured. Consequently, you must take an active role in upholding these principles inyour day-to-day activities.C. OBJECTIVES OF THIS CODEThis Code establishes what PAHO expects of you and what you can expect from PAHO.It describes our values and principles. This Code describes procedures to help you makeethical decisions and report and deal with violations of our values, principles, rules, andpolicies. To help you better use this Code, key words will be highlighted when they arefirst used and defined.This Code will help you:• Resolve doubts related to conduct and ethical behavior in the workplace;• Obtain confidential advice;• Understand how all of the Organization’s policies and procedures regardingconduct and ethics apply to you;• Feel confident that your conduct in dealings with people both inside and outsideof the Organization (such as governments, private businesses, business partners,vendors and suppliers) is appropriate and ethical; and• Bring suspected violations of the Code and other relevant Organization policiesand procedures to the attention of the appropriate persons in PAHO.Your adherence to this Code of Ethical Principles and Conduct represents a personal andprofessional commitment to PAHO’s values of equity, excellence, solidarity, respect andintegrity.D. APPLICABILITYThis Code applies to everyone who works in a PAHO workplace, regardless of the typeof contract held or the duration of appointment. By workplace we mean anywhere theOrganization’s work takes place or where we meet at the direction or invitation of thePAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 5

Organization. At the time you signed your appointment letter accepting employment withPAHO, you acknowledged that compliance with PAHO’s rules and policies constituteconditions of your employment with the Organization. Consequently, you are expected toknow and comply with this Code as well as other PAHO policies, regulations andprovisions that govern your conduct in the Organization, including:1. Article I of PAHO’s Staff Regulations pertaining to the duties, obligations andprivileges of staff members;See: https://intranet.paho.org/AM/HRM/StaffRulesEnglishJul2003.pdf2. Staff Rule 110 dealing with the standards of conduct of staff members;See: https://intranet.paho.org/AM/HRM/StaffRulesEnglishJul2003.pdf3. The International Civil Service Commission (ICSC) Standards of Conduct for theInternational Civil Service.See: http://icsc.un.org/resources/pdfs/general/standards.pdfWhile this Code does not apply to PAHO’s suppliers, vendors, contractors, and businesspartners working outside of our workplace, PAHO expects that they will familiarizethemselves with our Code and support effective conduct and ethics initiatives.This Code is effective as of 23 September 2005.E. ACKNOWLEDGEMENT AND AGREEMENTAn Acknowledgement and Agreement form is included at Appendix 1 to this Code. Ifyou work for PAHO, regardless of the type or duration of your contract, you must signthis form annually and return it to PAHO’s Ethics Officer. This form will be used toensure that you have read, understood and agreed to follow this Code.PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 6

II.ETHICAL FRAMEWORKA. MAKING ETHICAL DECISIONSIf you are having a difficult time deciding about your own conduct or if you are unsure ifthe actions of others are in compliance with this Code, answering these questions mayhelp you determine the right course of action:• Are my actions consistent with PAHO’s values?• Do I have all of the facts?• Have I reviewed the facts carefully?• Who will benefit from my actions?• What is the best decision for PAHO?• How will my decision reflect on PAHO?• What are the consequences of my choices?• How will my actions look to others?• Would I want my actions widely publicized?• Am I following the spirit as well as the letter of PAHO’s rules or policies?Never hesitate to ask questions, express concerns or make reports. The more we talkabout the ethical principles and conduct outlined in this Code, the clearer everyone willbe about what is expected. Feel free to consult your managers or supervisors if you areunsure about a decision, or consult any office or advisory body within our Integrity andConflict Management System (ICMS). You are not expected to have all the answers toethical issues that may come up in the course of doing your job, but you are expected toask for help if you have any doubt about what to do.B. THE INTEGRITY AND CONFLICT MANAGEMENT SYSTEM (ICMS)The Organization will establish an Integrity and Conflict Management System (ICMS)which identifies, describes and integrates the offices, advisory bodies and mechanismsthat handle staff inquiries, concerns, complaints and investigations into allegedmisconduct or violations of PAHO’s rules and procedures (a detailed description of theroles and responsibilities of ICMS entities is available at HYPERLINK TO BEPROVIDED). By organizing, integrating and managing its integrity and conflictmanagement resources into a single System, we will be better able to:PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 7

• Raise and handle concerns at the earliest opportunity, thus preventing andaddressing systemic issues ;• Establish consistent and clear standards about conduct, ethics and compliance;• Ensure consistent procedures for handling inquiries, complaints, allegations,and investigations;• Provide multiple confidential channels to ask questions, get advice and speakup about concerns; and• Provide education and training.ICMS Ethics ResourcesThe Integrity and Conflict Management System provides you with several access pointsor ICSMS Ethics Resources inside and outside the Organization to assist with yourethical concerns. You can turn to any of these resources if you have a question, needadvice, or wish to make a report about possible unethical behavior or misconduct. Whatis most important is that you feel comfortable getting the assistance you need.• The Ethics Office;• The PAHO Integrity HelpLine 1-888-448-4715;• The Office of the Ombudsperson;• The Office of Legal Counsel;• The Area of Human Resources Management;• The Office of Internal Audit;You may use any of these resources at any time or you may choose to speak to a manageror supervisor. If necessary, you may be referred to another person or office to ensure thatyour specific concerns are addressed.PAHO’S Ethics OfficerA key component of PAHO’s Integrity and Conflict Management System is PAHO’sindependent Ethics Officer, who reports directly to PAHO’s Executive Committee.While you will still have the option of requesting guidance or assistance from any of ourother ICMS ethics resources, the Ethics Officer plays a coordinating role and isresponsible for:• Promoting compliance with PAHO’s ethical standards;PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 8

• Providing training regarding this Code;• Responding to questions regarding what constitutes appropriate conduct;• Ensuring that PAHO’s policies and standards regarding ethical conductare current;• Ensuring that all staff sign and return the Code’s Acknowledgment andAgreement Form (Appendix 1);• Ensuring that inquiries and complaints received through PAHO’s IntegrityHelpline are promptly addressed;• Ensuring enforcement of this Code’s prohibition against retaliation;• Carrying out formal investigations of misconduct in order to ensureconsistency and neutrality in the investigative process;• Managing PAHO’s Declaration of Interest reporting program; and• Maintaining confidentiality.PAHO’S Integrity HelplineIn order to provide you with a confidential avenue for asking questions and reportingalleged violations of this Code, the Organization has established an Integrity Helplinewhich will be accessible to all staff. All calls to the Helpline are confidential, and youcan also opt to remain anonymous. The Integrity Helpline is a toll free call, availablethroughout PAHO Member States and managed by the Ethics Officer.PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 9

III. CREATING A CULTURE OF COMPLIANCEAND PREVENTIONA. PAHO’S PRIVILEGES AND IMMUNITIESThe privileges and immunities accorded the Organization by its Member States areintended not for your personal benefit, but to safeguard the independent exercise of yourofficial functions in connection with the Organization. Accordingly, the Organizationhas the right to waive the immunity of any staff member in any case where, in its opinion,the immunity would impede the course of justice and such immunity can be waivedwithout prejudice to the interests of the Organization.B. RIGHTS, RESPONSIBILITIES AND OBLIGATIONSAll Staff Members and Individuals Employed in PAHOIf you work for PAHO, you must:• Sign and submit the Code’s Acknowledgment and Agreement Form (Appendix 1)to the Ethics Officer;• Follow applicable rules and regulations and maintain the political neutrality ofinternational public service;• Give honest and impartial advice and make that information available to adecision maker;• Ensure proper, effective and efficient use of the Organization’s resources;• Ensure transparency while respecting the obligation to maintain confidentiality;• Perform your duties and arrange your private affairs so that confidence and trustin the integrity, objectivity and impartiality of PAHO are conserved andenhanced;• Avoid even the appearance of impropriety in all your actions, conduct, anddecisions;• While fulfilling your official duties and responsibilities, make decisions that are inthe best interests of the Organization and based on objective criteria;• Encourage, advocate and promote appropriate conduct and ethical behavior in theworkplace, and implement, monitor, and enforce PAHO’s Code and relatedpolicies in your own day-to-day work;PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 10

• Encourage PAHO’s partners to review this Code and to join PAHO in upholdingit;• Acknowledge that any person who wants to raise issues related to this Code hasthe right to do so and may approach any ICMS ethics resource without firstdiscussing the matter with his or her supervisor or manager. Managers and Supervisors in PAHOIf you are a manager or a supervisor you must also:• Uphold this Code and ensure you exhibit the highest level of ethical conduct at alltimes;• Be familiar with this Code and be able to explain to your staff their rights,responsibilities and obligations;• Encourage and allow your staff to participate in training activities sponsored bythe Organization on ethical issues; and• Handle confidentially and expeditiously any reported violation of this Code thatmay be brought to your attention, and ensure that others act accordingly. The OrganizationFor its part, the Organization must:• Provide staff with a copy of this Code and advise that they are required to read,understand and adhere to the Code as part of their employment contract with theOrganization;• Brief new staff on the Code during orientation sessions and provide current staffwith initial and recurrent training opportunities regarding the Organization’sethical standards;• Handle in confidence all reported violations of the Code;• Take timely action to investigate and respond to reported violations;• Take appropriate administrative or disciplinary measures in response to violationsof the Code;• Ensure that anyone who reports a suspected violations of the Code is not subjectto retaliation;PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 11

• Ensure that mechanisms and assistance are in place to help staff raise, discuss andresolve issues of concern related to the Code; and• Encourage and maintain an ongoing dialogue on values, conduct and ethics inorder to address specific issues and challenges as they arise within theOrganization.C. DUTY TO COMPLYPAHO places the utmost importance on the ethical conduct of everyone under its employ,and will not tolerate any violation of this Code or other policies, regulations andprovisions governing conduct within the Organization. Obeying this Code –both in itsspirit and its letter- is the foundation on which our ethical standards rest. Each of us has aduty to comply with PAHO’s rules and the laws of the nations in which we operate.Disciplinary MeasuresIf you fail to observe the provisions of this Code, or any standards of conduct outlined inArticle I of PAHO’s Staff Regulations; Staff Rule 110; or the ICSC Standards of Conductfor the International Civil Service, you will be subject to disciplinary measures.Depending on the gravity of the offense, you may be subject to one or more of thefollowing disciplinary actions:• Written reprimand;• Withholding of within-grade salary increase;• Suspension from duty without pay;• Reassignment with or without reduction in grade;• Dismissal for misconduct; and/or• Summary dismissal for serious misconduct.D. REPORTINGYou are encouraged to report known or suspected violations of this Code through any ofthe ICMS ethics resources. You may also report information received from othersregarding a suspected violation.ConfidentialityWe will take all appropriate steps to ensure that reports or concerns are handledconfidentially, but it is possible that the obligation to investigate or address violationsPAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 12

will override your wish for confidentiality, when for example, a person’s physical safetyor well-being is at stake.E. INVESTIGATIONSAll reported violations of this Code will be investigated as promptly, thoroughly andconfidentially as possible, in accordance with our written procedures. Investigations willgenerally be conducted by the Ethics Officer, although he/she may determine that anotherPAHO office (for example, the Legal Office, Internal Audit, Information Technology,Human Resources Management) should conduct or assist in the investigation. Ifnecessary, the Ethics Officer may bring in outside investigators or counsel to assist in theinvestigation. When appropriate, the Ethics Office will advise, in writing, the personmaking the report about the status of the investigation.Duty to CooperateYou must cooperate fully in informal or formal investigations of any alleged violation ofthis Code. You may not destroy or alter any documents, lie to or mislead investigators,or prevent collection of any information.F. PROHIBITION AGAINST RETALIATIONIt is a violation of this Code to retaliate against anyone who reports possible unethicalbehavior or misconduct to Organization authorities. “Retaliation” means harm done topersons in retribution for raising good faith concerns in the workplace.PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 13

IV. STANDARDS OF CONDUCTA. CONDUCT AFFECTING THE WORKPLACECultural SensitivityAs a multicultural organization, PAHO is committed to diversity and equality. Wesupport the right of all to express their individual cultural heritage, including languagesand religions. PAHO will not tolerate discrimination or lack of respect for any culture.You must be sensitive to the cultures of the countries where you work and understandlocal customs, including those involving personal behavior. You have a duty to contributeto the effective functioning of the workplace by treating colleagues and the public at largewith genuine respect. By virtue of PAHO’s international character, you must beparticularly sensitive to different cultural backgrounds, beliefs and opinions of peopleboth inside and outside of the workplace.Respect for Colleagues and OthersPAHO’s Policy on the Prevention and Resolution of Harassment in the Workplaceprohibits discrimination against or harassment of persons working within PAHO.Harassment makes the workplace unpleasant, humiliating or intimidating for the personor group targeted and reduces the effectiveness of everyone. You must treat all personsworking in the Organization with dignity and respect.Unwelcome sexual advances, requests for sexual favors, and other verbal or physicalconduct of a sexual nature constitute sexual harassment when this conduct explicitly orimplicitly affects employment, unreasonably interferes with work performance, or createsan intimidating, hostile, or offensive work environment. Such conduct will not betolerated in PAHO.PAHO’s Policy on the Prevention and Resolution of Harassment in the Workplaceprovides you with both informal and formal means of resolving complaints ofharassment. You can review PAHO’s Policy on the Prevention and Resolution ofHarassment in the Workplace at: http://intranet.paho.org/Display.asp?RecID=20600.Respect for National LawsYou must respect the laws, local regulations and cultural mores of the country where youare working. You should pay particular attention to laws and directions governing bankaccounts, currency dealings, purchase and disposal of motor vehicles, and trafficviolations. You must also satisfy all outstanding locally incurred financial debts prior tocompleting your posting or assignment.Moreover, while certain behavior and conduct may be acceptable in one country, theymay prove illegal or inappropriate in other countries. In particular, sexual activities andthe use of alcohol or drugs are sensitive areas which may easily be seen as offensive andPAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 14

equire you to ensure appropriate personal behavior in the local context. You areexpected to observe the highest standards wherever you are working.Personal ObligationsYou are solely responsible for the consequences of your failure to meet private legal orfinancial obligations (including payment of debts, taxes, rents, and spousal or childsupport obligations) or your failure to comply with applicable local laws. The privilegesand immunities attaching to PAHO are conferred in the interest of the Organizationalone, and furnish no excuse for you to avoid private obligations or breach national lawsor regulations. Failure to do so is a violation of this Code subject to disciplinary oradministrative action.Domestic EmployeesDomestic employees may either be local residents of the country where you are workingor foreign nationals under restricted visa arrangements for the specific purpose ofproviding personal services to you and/or your spouse. At all times you must complywith relevant standards regarding employment of locally-hired domestic employees. Ifyou are a staff member with a PAHO-sponsored domestic employee, you must submit acopy of a written employment contract to Human Resources Management (HRM),maintain proper employment records, and file annual statements summarizing wagepayments made during all calendar years. Domestic employees must also sign thesestatements.Romance in the WorkplaceConsensual intimate relationships between colleagues should not interfere with yourwork or create an environment where other persons working in the Organization mightfeel uncomfortable or disadvantaged as a result of your relationship. In cases where thereis a hierarchical relationship as well, one of the persons involved must requestreassignment or transfer to a different work unit.Violence in the WorkplacePAHO strives to provide a safe work environment for all staff and will never tolerateviolence or threats of any kind committed by or against someone working for PAHO.Additionally, the carrying of weapons on PAHO property, in PAHO vehicles, or anyplace where PAHO conducts business is strictly prohibited. This prohibition does notextend to host government law enforcement officials or authorized professional securitypersonnel at duty stations.Drugs and Alcohol AbusePAHO workplaces shall be free from illegal drugs and alcohol abuse. Staff must alwaysbe able to perform their duties free from the effects of prohibited drugs or alcohol.PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 15

Consequently, you must avoid any such behavior that prevents you from performing yourduties and work objectives, or that might bring the Organization’s reputation intodisrepute.With respect to business related meetings or social gatherings where alcohol is served,you must remember that you represent PAHO and act responsibly.If you have concerns or questions about drug or alcohol abuse, you may seek confidentialassistance through PAHO’s Employee Assistance Program by calling 1-800-765-0770.Assistance is available in both English and Spanish to all staff at PAHO Headquarters aswell as to staff in PAHO’s country offices and centers.Conduct of Family and Household MembersThis Code does not extend to your immediate family or household members. However,their actions can impact the Organization’s reputation and your ability to perform yourduties. Your immediate family or household member’s conduct within the PAHOworkplace or at official functions must conform to the ethical principles enunciated inthis Code. Persistent or serious misbehavior or breach of local laws by a family orhousehold member, or interference in official PAHO business, may result in thetermination of your posting.B. CONFLICT OF INTERESTSOverviewA “conflict of interest” occurs when your financial interests, business or socialcommitments, or personal or business relationships could reasonably interfere -or appearto interfere- with your ability to make fair and impartial decisions regarding the work ofthe Organization. Even if there is no evidence that you have done something improper, aconflict of interest can create an appearance of impropriety that can undermineconfidence in your ability to act properly or damage the reputation of the Organization.Avoiding and preventing even the appearance of a conflict of interest is one ofthe primary means by which you can maintain public confidence in the impartiality andobjectivity of the Organization. A “conflict of interest” exists when, for example:• There is a clash between your personal or private interests and your official publicresponsibilities;• You engage in a business or personal relationship that may not be in the bestinterests of the Organization;• You or your family have a business interest in an enterprise (possibly familyowned) which could compromise your loyalty to the Organization;PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 16

• Someone might reasonably question whether your official public actions ordecisions are influenced by your personal or private interests or the interests ofsomeone closely related to you by blood or marriage, friends or individuals withwhom you have a significant relationship or affiliation outside of PAHO;• You are in a position to use your contacts or position in the Organization toadvance your personal or private interests or those of someone closely related toyou by blood or marriage, friends, former colleagues or individuals with whomyou have a significant relationship or affiliation outside of PAHO;• You award a contract to an individual with whom you share personal or privaterelations, such as someone closely related to you by blood or marriage, friends,former colleagues or individuals with whom you have a significant relationship oraffiliation with outside of PAHO.• You offer or accept payment back to you (e.g. kickback), directly or indirectly, ofa portion of the purchase price by the seller to induce purchases, concessions,commissions and/or bonus; or may benefit from someone in the hopes of ensuringa particular decision or improperly influence future purchases.Any conflict of interest or even the appearance of a conflict of interest must be resolvedin favor of the Organization.Disclosing Conflicts of InterestIf you think that a real or apparent conflict of interest may exist, or if you have anydoubts in this regard about:(a) Your personal or private interests;(b) The interests of someone closely related to you by blood or marriage; or(c) The interests of friends or individuals with whom you have a significantrelationship or affiliation outside of PAHO;then you must immediately disclose all of the relevant facts to your manager orsupervisor or any of the ICMS ethics resources, before participating in any activities ortaking any decision about issues at hand. The Organization has the responsibility toconduct a timely evaluation of any real or apparent conflict of interest disclosed, andpromptly inform you of its decision.A person is “closely related to you by blood or marriage” if they are your mother, father,brother, sister, son, daughter, father-in-law, mother-in-law, son-in-law, daughter-in-law,sister-in-law, brother-in-law, grandmother, grandfather, grandson, granddaughter, uncle,aunt, nephew, niece, husband, wife, step-parent, step-child, step-brother, step-sister,guardian or ward.PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 17

Employment applicants may be asked to declare any real or apparent conflicts of interest.Before entry into the Organization, successful applicants may be required to divest anysuch interests to avoid conflicts.Declaration of InterestsYou must carefully evaluate on a regular basis whether your interests, as well as those ofimmediate family members comply with the conflict of interest provisions of this Code.The term “immediate family member” means your spouse, children, parents and siblingsand the children, parents and siblings of your spouse. In doing so, you must take intoaccount the nature of your official duties and the characteristics of your interests as wellas those of your immediate family members.You must immediately inform the Ethics Officer in writing if you or your immediatefamily members have any interest in or association with any entity with which you maybe required to have official dealings on behalf of the Organization, or which have acommercial interest in the Organization’s work or common areas of activity with theOrganization.You must also report any interest or association with entities whose policies, practices, orinterests conflict with those of the Organization, such as the tobacco industry andmanufactures of guns or other weapons.In addition to the above, staff in specific employment categories designated by theDirector of PAHO shall report annually to the Ethics Officer using PAHO’s Declarationof Interest Form as to whether they or their immediate family members have any of theabove referenced interests or associations. The categories of staff designated to submitsuch Declaration of Interest Forms, including those on acting appointments, are:• Executive Directors;• Area Managers;• Unit Chiefs;• All other staff at grade P6/D1 and above (inclusive) – referring to thegrade of the person not the grade of the post;• All professional staff in Procurement and Human Resource Management.Divestment of InterestsIf you are advised by the Organization that a conflict of interest exists and that you mustdivest yourself of a particular interest, you will be required to do so within 120 calendardays of being told to do so and must provide the Ethics Officer with evidence of thedivestment. Furthermore, you must do so through an arm’s length transaction, meaning aPAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 18

transaction conducted with someone who is acting independently of your own interests.Consequently, you may not sell or transfer financial interest, including personal assets, toan immediate family member for purposes of circumventing the compliance measuresoutlined above.Abstaining Where a Conflict of Interest ExistsIf you have a conflict of interest, you may not participate in any recommendation ordecision that would directly or preferentially benefit your personal, financial orprofessional interests, the interests of someone closely related to you by blood ormarriage, friends, former colleagues or individuals with whom you have a significantrelationship or affiliation outside of PAHO .Waiver of Conflict of InterestOnly PAHO can waive real or apparent conflicts of interest if it, at its sole discretion,determines that:• The situation is unlikely to adversely impact the best interests of theOrganization;• The conflict of interest is so remote or insignificant that it cannotreasonably be regarded as likely to influence you; or• The interests of PAHO outweigh the concern that a reasonable person mayhave regarding the integrity and/or objectivity of the activity in question.The measures outlined below are intended to minimize the possibility of a real orapparent conflict. Conflict of interest issues are particularly fact specific. As a result, itis not possible to describe every conceivable situation that could give rise to a conflict ofinterest. It becomes your responsibility to disclose the facts of any such situation and seekguidance if you harbor any doubt.Conflicts Due to Personal and Business RelationshipsYou may not use your position with PAHO for any private gain or personal benefit, theendorsement of any products, service or businesses, or for the private gain of any personclosely related to you by blood or marriage, friends, former colleagues or individualswith whom you have a significant relationship or affiliation outside of PAHO.Specifically, you may not directly or indirectly cause the Organization to enter intocontracts with:• Any persons:o closely related to you by blood or marriage;PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 19

o with whom you are involved in a significant personal relationship; or• Companies, entities, organizations or associations where:o anyone closely related to you by blood or marriage or with whom you areinvolved in a significant personal relationship was previously or iscurrently an officer, director, owner, trustee, general partner, agent,attorney, consultant, contractor or employee;o someone with knowledge of relevant facts could reasonably question yourimpartiality in causing the Organization to enter into the contract.In all instances, you must ensure that your procurement actions comply with PAHO’sProcurement Procedures Manual, which you can view and download at:https://intranet.paho.org/AM/PRO/PRO.asp. If you have questions or doubts regardingcontracting situations that may affect, or be perceived as affecting, your objectivity orimpartiality, you must consult with any of the ICMS ethics resources.Hiring of Spouses and Family MembersThe Organization may employ your spouse if, after conducting a competitive selectionprocess, your spouse is the best candidate.. However, your spouse may not serve in thesame unit as you and cannot be in a supervisory or subordinate position to you.The Organization will not normally employ a person who is closely related to you byblood or marriage. If you become aware that a person closely related to you by blood ormarriage, has applied for a position with the Organization, you must immediately advisethe Area of Human Resources Management.However, under no circumstance may you participate in any activity that involves thehiring, advancement, promotion or evaluation of your spouse or of anyone who is closelyrelated to you by blood or marriage or with whom you are involved in a significantpersonal relationship.Gifts from Sources Outside of PAHOGifts given to you by anyone outside the Organization for activities and/or events relatedto your official duties may only be accepted if:• The gift is infrequent and of minimal value (low-cost promotional objects,simple meals, souvenirs with no cash value); and• The gift does not compromise or in any way appear to compromise yourintegrity or that of the Organization.PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 20

Otherwise, you may not, directly or indirectly, solicit or accept any gift from anyoneoutside the Organization who may be in a position to influence your objectivity incarrying out your official duties or that may place you under obligation to the persongiving the gift.The term “gift” includes any cash, gratuity, favor, discount, entertainment, admission tosporting and cultural events, hospitality, loan, or any other benefit or item havingmonetary value. Such shall include services and/or gifts of training, transportation, travel,lodgings and meals, whether provided in-kind, by purchase of a ticket, payment inadvance, or reimbursement after the expense has been incurred.An “indirect gift” means a gift given with your knowledge and acquiescence to someoneclosely related to you by blood or marriage, or someone with whom you have a closepersonal relationship, because of that person’s relationship to you. Indirect gifts alsoinclude gifts given to persons or entities, including any charitable organizations, based onyour designation, recommendation, or direction.If it is not possible to decline a gift or if there is sufficient benefit to the Organization towarrant acceptance of a gift, you must immediately seek written direction from the EthicsOfficer, who will notify you in writing as to whether you or the Organization can keepthe gift, whether the gift must be declined, or whether the gift can be donated to charityor must otherwise be disposed of.Gifts between People Working for PAHOAs a general rule, you may not directly or indirectly give gifts to or solicit contributionsfrom another person for gifts, or make donations towards gifts for a supervisor or anindividual in a position of authority.You may give gifts to or accept gifts from other persons working in PAHO only if eachof the following circumstances is satisfied:• You and the other person are not in a supervisor-supervisee relationship. Still,you may give gifts appropriate to the occasion to your supervisor or accept giftsfrom someone you supervise;o In recognition of infrequently occurring occasions of personal significancesuch as marriages, illnesses, or births or adoptions of children; oro Upon occasions that terminate the supervisor-supervisee relationship, suchas retirements, resignations, or transfers.• There is a personal relationship between you that would justify such gifts;• Gifts are of nominal value; andPAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 21

• Gifts are given on special, infrequent occasions.Awards and Honorary DecreesYou may accept awards from outside sources provided that such are not accompanied byany form of cash payments, investment interests, or gifts with more than nominal values.Otherwise, you must have written authorization from the Ethics Officer.You may accept honorary degrees from institutions of higher education provided that thetiming of the award of such degree does not call into question your impartiality in mattersaffecting the Organization.In accepting awards or honorary degrees, you may also accept meals and entertainmentgiven you and members of your family at the event at which presentations of such awardsor degrees takes place.Relations with Governments and Political ActivityWhile you clearly have an obligation to maintain the best possible relations withGovernments of PAHO Member States, you should not interfere with their policies oraffairs. In order to maintain the impartiality of the international civil service, you mustremain independent of any authority outside of the Organization and your conduct mustreflect that independence. For this reason, you may not seek or obtain, under anycircumstance, instructions or assistance from any Government official or from any otherauthority external to the Origination, particularly in an attempt to:• Interfere with the internal deliberations of the Organization;• Change a possibly unfavorable action or decision, such as non-renewal ofyour employment contract, or your separation or termination from theOrganization; or• Obtain any promotion, benefit or any other type of advantage.Likewise, you must refrain from actions that could be viewed as critical or intended todiscredit a Government, or that might interfere with Governmental policies or affairs.Because of the independence and impartiality of international civil service, you may notparticipate in political activities, including running for or holding local or nationalpolitical office, while you are under PAHO’s employ. Additionally, while you may voteand belong to political parties, you must exercise discretion at all times in your personalpolitical activities and may not participate in fundraising or other campaign activities onbehalf of other persons.PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 22

Employment and Activities Outside of PAHOYour primary obligation as an international civil service is to devote your energies to thework of the Organization. You may engage in employment or activities outside of PAHOwhich do not pose a conflict with your official duties or responsibilities, and whichare compatible with the work and reputation of the Organization.If you wish to engage in any paid or unpaid employment or activity outside of theOrganization, you must submit a written request to HRM for approval prior tocommencing that employment. HRM, after consultation with your supervisors, mayrequire that the outside employment or activity be curtailed, modified or terminated if itis determined that a real or apparent conflict of interest exists.Participation in Professional AssociationsYou may not receive compensation from any source other than PAHO for work(including teaching, speaking or writing) that relates to your official duties. Work relatesto your official duties if:• The activity is undertaken as part of your assigned work objectives orresponsibilities; or• The circumstances indicate that the invitation to engage in the activity wasextended to you primarily because of your official position rather than yourexpertise in the particular subject matter.If you are engaged in teaching, speaking or writing as outside employment or as anoutside activity you may not use or permit the use of your official title or position atPAHO to identify yourself in connection with the outside activity or to promote anybook, seminar, course, program or similar undertaking, except that you may:• include or permit the inclusion of your title or position as one of severalbiographical details to identify you, provided that your title or position isgiven no more prominence than your other biographical details;• use, or permit the use of, your title or position in connection with an articlepublished in a scientific or professional journal, provided that the title orposition is accompanied by a reasonably prominent disclaimer satisfactory tothe Organization stating that the views expressed in the article do notnecessarily represent the views of PAHO.Post PAHO EmploymentThere are no restrictions on the types of employment you may obtain after leaving theOrganization. However, as soon as you know that you will be leaving PAHO, you mustdisclose in writing to your supervisor and the Area of Human Resources ManagementPAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 23

any real or apparent conflicts existing between your new job and your most recentposting within PAHO.Note that certain restrictions will apply if you wish to return to work at PAHO afterobtaining a termination indemnity or a separation by mutual agreement.You may use skills, knowledge and experience gained at PAHO in your newemployment. However, you may not disclose, publish or communicate confidentialPAHO information, without PAHO’s authority.We expect former PAHO employees and retirees to refrain from taking undue advantagefrom their former relationships with PAHO and its staff.C. USE OF PAHO’S PROPERTY AND RESOURCESOverviewYou must be extremely careful and vigilant in the use of the Organization’s property andresources, including its time, money, credit cards, goods, services, vehicles, officeequipment, official records (including electronic records), telecommunications andinformation technology applications. You must never use the Organization’s resourcesfor private gain.You should only use the Organization’s property for official purposes. You have a dutyto protect and conserve PAHO property and use it only for authorized purposes.Under no circumstances should you conduct private business of any kind (includinglending or borrowing money, or pyramid schemes) on PAHO property, premises andfacilities.PAHO Name and LogoPAHO’s name and logo are internationally registered and protected. Anyone outside ofPAHO wishing to use PAHO’s name or logo must submit a written request to PAHO’slegal office with a full justification and, for a publication, to PAHO’s Office ofPublications as well. Typically, PAHO permits the use its name and logo whenever:• Legal relationships exist between requesting organizations and PAHO, orwhenever such requests relate to activities having received financial or othersupport from PAHO; and• It can be shown that allowing such use will further the aims of PAHO.Otherwise, PAHO generally refuses permission to use its name and logo whenever itmight be misconstrued, especially where this might imply PAHO’s support orendorsement of commercial interests.PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 24

Intellectual PropertyAll rights, including title, copyright and patent rights, in any work or invention youproduce or develop as part of your official duties belong to the Organization. Whileauthors shall be given credit for publications of a technical character, the Organizationhas the right to decide where and how to offer for publication any professional ortechnical paper produced in the course of your duties. In carrying out your dailyresponsibilities, you must strive to protect PAHO’s intellectual property by ensuring thatyou understand and comply with PAHO’s policies on the use, disclosure, release,reproduction, translation, distribution or licensing of PAHO’s intellectual property andthat you report any unauthorized release or use to the Legal Office. You will findPAHO’s policies on this matter at: https://intranet.who.int/sd/cgibin/om_isapi.dll?&infobase=Manual&softpage=Browse_Frame_pgPAHO information is valuable property, intended for official use only. In performingyour official duties in PAHO, you may come across or be given official access toconfidential or privileged information regarding the Organization, its staff, its partners, itssuppliers or others. Unauthorized disclosure of confidential or privileged informationmay seriously impact the efficiency and credibility of the Organization. Consequently,you must ensure that you do not intentionally or accidentally share confidential orprivileged information with unauthorized parties or use such information for yourpersonal benefit, the benefit of someone closely related to you by blood or marriage, orthe benefit of someone with whom you have a close personal relationship.In addition, you must respect the intellectual property rights of other entities. PAHO willnot tolerate the unauthorized use, disclosure, release, reproduction, translation, ordistribution of such information. You may only use the intellectual property of otherentities upon having first obtained their consent or when such is publicly availablewithout restriction.Internal ControlsIt is crucial that PAHO maintain accurate record keeping and internal control systems.As such, you must record all transactions and prepare accurate and complete records, inaccordance with established procedures. It is inappropriate, for example, to inaccuratelyrecord time for reporting purposes, provide false or intentionally misleading informationto the Organization, submit false or misleading invoices or vouchers, or falsify anyofficial PAHO documents.Use of Official TimeThe official workweek of the Organization for full time work is 40 hours. Unlessauthorized to use working hours for other purposes or unless you are on officiallyrecognized leave, you must use this official time in an honest effort to perform yourassigned duties. No other activity or responsibility may conflict with this obligationPAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 25

unless specifically approved in writing by your supervisor with a copy of that approvalbeing sent to HRM.You may not request, promote, direct or attempt to coerce or influence other persons touse official time to perform activities other than those required in the performance oftheir official duties.Use of Office TechnologyPAHO telephones, computers, email, internet, and other technologies may only be usedfor legitimate business purposes. PAHO reserves the right to monitor and review allinformation contained in these systems and verify how such systems are being used.Although these systems are provided to help you meet official responsibilities, you maywithin reason use PAHO telephones or other resources such as e-mail, Internet, voicemail, faxes and computers for limited personal use. You may not make personal longdistancetelephone calls or incur any other charges related to your use of Organizationassets for personal reasons, if such charges ultimately accrue to PAHO. If there is apersonal emergency or some other well-justified reason to use the Organization’s longdistanceservice for personal calls, you must first inform your supervisor and promptlyreimburse the Organization for the costs of such calls. You may view your monthly longdistancecharges at: https://intranet.paho.org/AGS/TelDirFr.asp .Computers are provided to persons working in the Organization in order to do their work.While email may encourage informality, these messages are official records and may beretrieved and used by the Organization whenever necessary. You must ensure that emailsare accurate and their language and tone appropriate. Furthermore, you are prohibitedfrom using PAHO’s information technology resources to access, send, or forwardmaterial that is harassing, obscene, sexually oriented, or defamatory.Motor VehiclesThe Organization’s vehicles are available for official use only. In exceptional caseswhere a person has been authorized to use a vehicle belonging to the Organization forprivate purposes, an appropriate reimbursement shall be made according to establishedmileage rates.Frequent Flyer PointsPersons working for the Organization may join a frequent flyer scheme and retain forpersonal use the points that they have accrued while traveling on official business.PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 26

NOTESPAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 27

NOTESPAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 28

Appendix 1Acknowledgement of Receipt FormSTATEMENT OF ACKNOWLEDGMENT AND AGREEMENTI have read and understood, and I will comply with PAHO’s Code of EthicalPrinciples and Conduct, the International Civil Service Commission Standards ofConduct for the International Civil Service, and Article I and Staff Rule 110 ofPAHO’s Staff Rules and Staff Regulations. I understand that any failure on mypart to comply with these requirements will result in disciplinary action being takenagainst me under Staff Rule 1110, regardless of whether I choose to sign thisacknowledgment statement or not.Signature:_____________________________________Print or type name:______________________________Area and Unit:_______________________________Date: ___________________________________________PAHO INTEGRITY HELPLINE 1 - 888 - 448 - 4715 29